Supreme Court of the United States, 2011

The Supreme Court held that securities fraud plaintiffs need not prove loss causation in order to obtain class certification under Federal Rule of Civil Procedure 23(b)(3), vacating the Fifth Circuit judgment that had imposed such a requirement.

Justice Breyer dissenting, argues the Court's reading of the Bayh-Dole Act permits individual inventors to bypass statutory assignment rules by separately assigning rights to third parties.

The Supreme Court held that the Bayh-Dole Act does not automatically vest title to federally funded inventions in federal contractors; inventors retain their rights unless they assign them to another party.

The Supreme Court held that a prevailing defendant may recover attorney's fees under 42 U.S.C. § 1988 even when the plaintiff asserted both frivolous and non-frivolous claims, but only for fees the defendant would not have incurred but for the frivolous claims.

The Supreme Court held that under the Armed Career Criminal Act, the maximum term of imprisonment for a prior state drug offense is the maximum sentence applicable at the time of the defendant's state conviction.

Chief Justice Roberts, writing for seven Justices, held that the Bayh-Dole Act neither automatically vests title to federally funded inventions in federal contractors nor authorizes contractors to take title unilaterally.

Justice Kennedy joined the Court's opinion fully but concurred in full, noting the Government's use of the material-witness statute raises unresolved lawful authority and Fourth Amendment questions, and arguing national officeholders should receive qualified immunity deference for jurisdictional inconsistency.

The Supreme Court held that an objectively reasonable arrest and detention of a material witness pursuant to a validly obtained warrant cannot be challenged as unconstitutional on the basis of allegations that the arresting authority had an improper motive, because Fourth Amendment reasonableness is predominantly an…

The Court held that an objectively reasonable arrest and detention under a validly obtained material-witness warrant cannot be rendered unconstitutional solely by an allegation of improper motive, and that Ashcroft was entitled to qualified immunity because no clearly established law prohibited the alleged conduct.

Justice Ginsburg concurred in the judgment, agreeing no clearly established law rendered Ashcroft liable for damages. She argued the Court should not have resolved al-Kidd's Fourth Amendment claim on the merits as that was unnecessary for the outcome.

Justice Sotomayor concurred in the judgment reversing the Court of Appeals because Ashcroft did not violate clearly established law, but she criticized the majority for unnecessarily resolving a novel Fourth Amendment question regarding pretextual use of material witness warrants.

Justice Kennedy, dissenting, argues that the Court's decision creates an unwarranted exception to the prevailing-party rule by allowing review of non-binding constitutional dicta in qualified immunity cases.

Justice Scalia concurs in part and in the judgment, agreeing that a pretrial motion's pendency excludes time under the Speedy Trial Act without requiring actual trial postponement. He argues the text is clear and requires no inquiry into whether a delay was expected or caused, contrary to the Sixth Circuit's view.

Sotomayor concurred in the judgment, agreeing the case is moot and vacatur is appropriate. She argued the Court should not reach the difficult question of whether a prevailing party can obtain review of a constitutional ruling when no case or controversy exists.

The Court held that Arizona's Legal Arizona Workers Act is not preempted by federal immigration law. Its licensing sanctions fall within the express savings clause for licensing and similar laws, do not conflict with the federal employment-sanctions scheme, and its E-Verify mandate is not impliedly preempted because…

The Court held that the Speedy Trial Act's exclusion for pretrial motions applies automatically without a causation requirement, but affirmed the Sixth Circuit's judgment because the lower court correctly excluded holidays and weekends when calculating transportation delays under a different provision.

The Court held that the Speedy Trial Act's exclusion for pretrial motions applies automatically upon filing regardless of whether they actually caused trial delay, and that the exclusion for transportation includes weekends and holidays in its 10-day limit.

Government officials who win on qualified immunity can generally seek Supreme Court review of adverse constitutional rulings, but this case was moot because the plaintiff had grown up and moved away; thus the Court vacated the Ninth Circuit's Fourth Amendment holding.

Justice Alito, dissenting, argues the lower court’s order to release 46,000 prisoners violated the PLRA and exceeded constitutional authority by relying on outdated evidence and failing to weigh public safety. He contends the relief was not narrowly tailored to remedy specific constitutional violations.

The Supreme Court affirmed a three-judge court order requiring California to reduce prison population to 137.5% of design capacity. The Court held the Prison Litigation Reform Act (PLRA) authorizes such relief where overcrowding is the primary cause of Eighth Amendment violations and no other remedy exists.

The Supreme Court affirmed a three-judge district court's order requiring California to reduce its prison population to 137.5% of design capacity within two years, holding that the Prison Litigation Reform Act authorizes the relief and that the population limit is necessary to remedy longstanding Eighth Amendment…

The Court held that a federal agency's written response to a FOIA request constitutes a "report" within the meaning of the False Claims Act's public disclosure bar. It reversed the Second Circuit, which had held such responses were not reports, because the ordinary meaning of "report" includes something that gives…

The Court held that a federal agency's written response to a FOIA request constitutes a report under the False Claims Act public disclosure bar, reversing the Second Circuit. Justice Ginsburg dissented, arguing that this limits whistleblowers' ability to substantiate claims.

Justice Scalia concurs in the judgment, agreeing that ERISA § 502(a)(1)(B) does not authorize relief for misrepresentations in a summary plan description. He argues the majority unnecessarily addressed § 502(a)(3) equitable relief issues that the District Court avoided.

The Court held that ERISA §502(a)(1)(B)—which lets participants recover benefits due under their plan's terms—did not authorize the District Court to reform CIGNA's cash-balance plan, because that provision enforces plan terms rather than changing them and summary plan descriptions are communications about the plan…

Justice Scalia dissents, arguing the majority erroneously interpreted the Yellowstone River Compact to allow Wyoming to increase water consumption without reducing return flows to Montana.

The Court held that the Yellowstone River Compact does not prohibit Wyoming from allowing pre-1950 water appropriators to improve irrigation efficiency, even if this increases consumption and reduces return flows to Montana.

The Court reversed the Ninth Circuit, holding the Federal Arbitration Act preempts California's Discover Bank rule that deemed class-action waivers unconscionable. The majority found class arbitration interferes with the informality and efficiency that are fundamental to arbitration agreements.

The Court, in an opinion by Justice Scalia joined by Chief Justice Roberts and Justices Kennedy, Thomas, and Alito, held that the Federal Arbitration Act preempts California’s Discover Bank rule invalidating certain consumer arbitration agreements that prohibit classwide proceedings.

The Court held that the Federal Arbitration Act preempts California's Discover Bank rule, which classifies most class-action waivers in consumer contracts as unconscionable. The opinion reasons that requiring classwide arbitration interferes with the fundamental attributes of arbitration and obstructs the FAA’s…

Justice Thomas concurred to explain his textual reading that the Federal Arbitration Act permits contract defenses only when they relate to the formation of the arbitration agreement, such as fraud or duress, rather than public policy defenses.

Justice Breyer, dissenting, argues that the Federal Arbitration Act does not preempt California's Discover Bank rule, which renders class-action waivers in consumer contracts unconscionable. He contends the rule fits within the FAA's saving clause because it applies to all contracts equally.

The Court held that the Federal Arbitration Act preempts California’s Discover Bank rule, which classifies most class-arbitration waivers in consumer contracts as unconscionable.

Justice Thomas concurring, argues that Section 2 of the Federal Arbitration Act limits state-law defenses to those challenging contract formation, such as fraud or duress, and thus preempts California's Discover Bank rule because it concerns general unconscionability rather than formation defects.

Justice Sotomayor dissents, arguing the majority wrongfully finds ambiguity in the term “appropriate relief” in RLUIPA. She contends general remedies principles and precedents like Franklin make clear monetary damages are included, and denying them undermines congressional intent to provide broad protections for…

The Supreme Court held that States, by accepting federal funds, do not consent to waive their sovereign immunity to private suits for money damages under the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), so sovereign immunity bars petitioner's damages claim against Texas.

The Court held that the Eleventh Amendment does not bar a suit by an independent state agency against state officials in federal court for prospective relief under Ex parte Young. The Court reasoned that the doctrine depends on the relief sought rather than the identity of the plaintiff. Justice Kagan took no part.

Chief Justice Roberts dissents, arguing that the Ex parte Young fiction should not be extended to a state agency suing officials of the same state in federal court, due to sovereign immunity concerns and the novelty of such suits.

Justice Kagan dissents, arguing that taxpayers have standing under Flast v. Cohen to challenge the Arizona tuition tax credit under the Establishment Clause. She contends the majority's distinction between appropriations and tax expenditures is without precedent and undermines judicial review of government…